[Pharmwaste] RE: Air Quality? Pharmwaste Digest, Vol 45, Issue 13

[Rudy Vingris]

I am writing in response to Sarah Holcomb's question about studies of air
quality from the incineration of pharmaceuticals.  I don't know of any
specific studies but I would like to provide the following thoughts on your
comments of compliance with RCRA.  

If the envisioned incinerator is going to be used to incinerate any RCRA
hazardous waste pharmaceutical, it will need to meet all the requirements
for TSDF and hazardous waste incinerators found in 40 CFR. 261.  These are
extensive and complex requirements.  I do not believe that the cost to
comply with these regulations could be justified in a small scale project to
incinerate a small amount of RCRA pharmaceutical waste.  In addition to RCRA
the incinerator would also have to meet Air Pollution regulations (most
likely a Title V permit) to burn any type of waste.  

I think it would be much more cost effective to make use of existing
commercial capacity to destroy these wastes.  

Rudy Vingris
Consultant


-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of
pharmwaste-request at lists.dep.state.fl.us
Sent: Thursday, July 30, 2009 9:17 AM
To: pharmwaste at lists.dep.state.fl.us
Subject: Pharmwaste Digest, Vol 45, Issue 13

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